Insights

The Supreme Court of the United States has held that inherited IRA assets are not exempt from bankruptcy claims by an inheriting individual beneficiary’s creditors. In estate planning, the Supreme Court opinion may make it more desirable to name a trust as IRA death beneficiary, rather than naming an individual…

If you received an email or letter from an attorney or CPA in the last decade, you probably have seen a Circular 230 disclaimer. Since 2004, the Internal Revenue Service has required that almost all written communications from tax practitioners concerning federal tax matters include this disclaimer notifying the reader that…

We have discussed a structuring technique real estate investors use to protect the lower-federal-income-tax-rate-long-term-capital-gain treatment of real estate gains, before property is converted to an active development purpose that creates higher-tax-rate income. The structuring requires property transfers and the use of multiple business entities, which decreases transparency for the government…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of–money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2014: Short Term AFR…

In January we noted a new Tax Court case, Pool v. Commissioner, addressing the boundaries of a structuring technique real estate investors use to protect the lower-federal-income-tax-rate-long-term-capital-gain treatment of real estate gains, before property is converted to an active development purpose that creates higher-tax-rate income. Tax Court Sets Boundaries For Predevelopment Capital…